HomeMy WebLinkAbout057SUBSURFACE GROUP LLC
PMB 154, 1992 S Elger bay Road.
Camano Island, Washington 98282
(360)631-5600
MEMORANDUM
To: Garth Mann, Tom McDonald
From: Scott Bender Scott, Thank you for your response to my comments. I will have to rely
on your expertise to adequately address the concerns related to the
CC: Craig Peck effects of this project on the aquifer. I also understand that Ecology has
Date: December 1, 2010 already reviewed this project and approved the water rights. I've limited
RE: REVISED RESP my responses accordingly. - Susan
SUSAN PORTO, JEFFERSON COUNTY PUBLIC HEALTH
We are in receipt of comments made by Ms. Susan Porto of the Jefferson County Department
of Health. This memorandum provides some additional information and clarifies some of
initial responses. We provide the following responses:
Pleasant Harbor Golf and Marina Neighborhood Water Supply Program
Monitoring Plan
a) Of the twelve domestic off-site wells sampled
concentrations in excess of 200 mg/1, which ui
classifies them as `High Risk' wells. Ecology
the County, who then incorporated that info
database. Under the program, a 1,000 -foo dig
around the well in question; anyfuture gr and
withdraw groundwater from within this one r.
protective measures" to prevent a furt r incre
Your statements in this regard were ,
"The existing well has supplied water
at similar to proposed rates with no
adverse impacts (chlorides = zero." I
don't understand how a pump test
can be equated to "similar rates" that
are proposed by this
copy of the County's map is/ahYou will see that a very small part of
the protective zone falls on tnt Harbor property. Our proposed
monitoring well MW -8 is jur outside of the boundary. Our water
supply wells will be over 1,way from the edge of the protective
zone. It is my understandine proposed water supply well is outside
of that 1,000 protective zonenew measures are necessary. Ms. Porto
issues the comment for clariI believe no further action on our part is
necessary.
b) All items in Monitoring P an Item 1 will be performed at on-site wells only.
Off-site well monitorin s addressed in the Monitoring Plan. There is no plan
to install flowmeters off-site domestic wells.
c) Water quality sample were collected during pumping of the American
Campground well during the pumping test, and from MW -2. The analysis
reports are attached.
SUBSURFACE GROUP, LLC SG0601-02
Memorandum to Statesman Corporation
December 1, 2010
Page 2
d) The hydrogeologic analysis referred to is presented in our Draft Water Supply
and Groundwater Impact Analysis Report dated December 17, 2008. That
report contains a narrative of our understanding of the aquifer and aquifer
conditions, as well as supporting water level and pumping test data.
2. The wells described in Item (d) and shown on Figure 1 of the Monitoring Plan
map cover the resort, concentrating on the borders of the property. The intent is
to monitor groundwater drawdown, which given sufficient drawdown for an
extended period of time is the principle indicator of the potential for sea water
intrusion. It is our opinion that the number of wells is more than adequate. The
depth of the wells is also adequate to monitor for these purposes. In addition, the
American Campground well is an exceptionally deep well; monitoring of
groundwater quality from this well will provide an understanding if upwelling of
saltwater could be occurring. As the project will be introducing more water into
the aquifer, we do not believe that a "potential [for] widespread lateral sea water
intrusion" exists; however, we have built a monitoring program and contingencies
to address the concerns of the community and to protect the water supply of the
community and resort itself. —Frm not familiar enough with the
3. Recharge Areas: We consider an `impact' as exceeda ce
`High Risk' levels presented in the County's SIPZ po cy
identify impacts in paragraph 4(b) of the attached Fe rua
Water Supply Program. Our opinions regarding the Pte
impact are summarized on Page 18 of our Decembe200
report cited above.
details of your project to
adequately comment on this.
My overall concern is whether
you have planned adequately
for drought years and the
limitations of recharge.
4. As noted in pages 16 through 18 of our December 008 report, the hydraulics of
the resort will be such that there will be more grou dwater recharge to the aquifer
during operation of the resort than presently occu . This is largely a function of
collecting water from the roof tops and roadways and infiltrating it before the
water can evaporate be consumed by vegetation. Infiltration galleries will be
constructed beneath the golf course fairways that will be used to infiltrate excess
stormwater. These galleries will be placed around the resort to enhance aquifer
recharge. Attached is a preliminary facility map in which we have set aside
recharge areas as infiltration galleries.
5. At this time there have been many mitigation measures already incorporated into
a water supply plan that shows a net benefit to the aquifer. Beyond all of those
measures, there are options to add additional wells that will pump at lower
individual rates, to focus groundwater recharge to areas of concern, or even to
treat surface water. In our opinion these are suitable mitigation measures for
SUBSURFACE GROUP, LLC SG0601-03
Memorandum to Statesman Corporation
December 1, 2010
Page 3
planning purposes, and the appropriate measures will be taken to protect the
community's and resort's water supply should a situation arise.
6. Water Supply Replacement:
a) We are not aware of the mitigation plans presented to be in violation of any
state law or policy. Based on our understanding of the hydrogeology beneath
Black Point, the monitoring and mitigation plans offered by the resort are
proactive and conservative.
b) As we have discussed with Ecology I don't believe you gh other
conditions of the water monitori prc have answered my ndations are
unZMarina
difficult to im menta concerns here. To
c) Tg program as designed reiterate a portion influence from
thply wel . This is a very he drawdown
of my comment
dainst mentation will pro from 3/26/10, "...and tanding of the
drcts from the wells. a recorded notice to
title be executed to
allow agency and
isant HarbMarina Groundwater Mor Resort access for the
purpose of
1. 6ffsite wells will be identified as the prof implementing the plan. t stage.
2. The Gaul well can be considered for moni ring of a well
with existing poor water quality may not Have value, ai rea y has been
compromised by construction or operation. Doesn't it seem like
3. The water rights provided in the permit from Ecology have
with sufficient quantity for the development. The delivery, that stability is a
neighborhood plan to adversely impacted well owners, if function of the fact
by obtaining and consolidating the water rights perfect b that the well had
owners. very little use during
4. The process for addressing impacts to other groun ater u those years?
monitoring plan. Pleasant Harbor will use and s re the groundwater data
collected from the resort's monitoring network s part of an impact assessment.
5. Groundwater monitoring at the site has show stable groundwater levels even in
very low water years such as 2006 and 2008. Surface water storage will be
sufficient to supply more than one year of irrigation supply; however, the long-
term precipitation data do not provide any indication that the surface water
storage will not be replenished even in a dry winter.
SUBSURFACE GROUP, LLC SG0601-03
Map Output Page 2 of 2
http://maps.co. j efferson.wa.uslservlet/com. esri.esrimap.Esrimap?ServiceName=ovmap_outs... 4/6/2010
Am Test Inc.
14603 N.E. 87th St.
Redmond, WA 98052
(425)885-1664
www.amtestiab.com
AMF.S_T__
L A 0 0 A A T O R I E 3
Drinking Water Report for IOC's
Professional
Analytical
Services
System ID No.:
System Name:
Lab/Sample No: 06605782
Date Collected: 05/19/2008
DOH Source No: S03
Multiple Source Nos.:
Date Received: 5/20/08
Sample Type: Sample Purpose:
Date Reported: 5/23/08 Supervisor: AY
Date Digested:
Date Analyzed (Nitrates):
Analyst:
County: Jefferson
Group:
Sample Location: 5/19/08 2100 American Campground
Send Report To: Bender Consulting
630 6th St S
Kirkland, WA 98033
BOI,To: Scott Wrier
636 6th St S
Kirkland, WA 98033
EPA Raemlafael'tSacnndarvl .40C's
DOH#
jAnalytes lResults
Units SRL ITrigger
liCL
JE.ceeds MCL
Method
Analyst
21
Chloride ND
mg/I 20. 250
250
NO
300.0
MO
NOTES:
SRL (State Reporting Levet): indicates the minimum reporting level required by the Washington Department of Health (DOH)
Trigger Level: DOH Drinking Water response level. Systems with compounds detected at concentrations in excess of this level are
required to take additional samples. Contact your regenional DOH office for further information.
MCL (Maximum Contaminant Level): If the contaminant amount exceeds the MCL, immediately contact your regional DOH office.
NA (Not Analyzed): in the results column indicates this compound was no included in the current analysis.
ND (Not Detected): in the results column indicates this compound was analyzed and not detected at a level greater than or equal
to the SRL.
<(0.001): indicates the compound was not detected in the sample at or above the concentration indicated.
LA�- \A
lan X.Young
Laboratory Manager
Am Test Inc.
14603 N.E. 87th St.
Redmond, WA 98052
(425) 885-1664
www.amtestlab.com
L A B O R A T O R I E S
Drinking Water Report for IOC's
System ID No.:
Professional
AW
MT
DOH Source No: S03
Analytical
Services
L A B O R A T O R I E S
Drinking Water Report for IOC's
System ID No.:
System Name:
Lab/Sample No: 06605782
Date Collected: 05/19/2008
DOH Source No: S03
Multiple Source Nos.:
Sample Type:
Sample Purpose:
Date Received: 5/20/08
Date Reported: 5/23/08
Supervisor: AY
Date Digested:
Date Analyzed (Nitrates):
Analyst:
County: Jefferson
NO
Group:
Sample Location: 5/19/08 2100 American Campground
Send Report To: Bender Consulting
630 6th St S
Kirkland, WA 98033
Bill To: Scott Bender
.630 6th St S
; = `ftland; WA 98033
EPA Reaulated (Secondary) - IOC's
DOW
Analytes
Results
Units SRL
Trigger
MCL
Exceeds MCL
IMethod
Analyst
21
Chloride
IND
I mg/1 20.
250
250 1
NO
1300.0
MO
NOTES:
SRL (State Reporting Level): indicates the minimum reporting level required by the Washington Department of Health (DOH)
Trigger Level: DOH Drinking Water response level. Systems with compounds detected at concentrations in excess of this level are
required to take additional samples. Contact your regenional DOH office for further information.
MCL (Maximum Contaminant Level): If the contaminant amount exceeds the MCL, immediately contact your regional DOH office.
NA (Not Analyzed): in the results column indicates this compound was no included in the current analysis.
ND (Not Detected): in the results column indicates this compound was analyzed and not detected at a level greater than or equal
to the SRL.
<(0.001): indicates the compound was not detected in the sample at or above the concentration indicated.
A
n W. Young
Laboratory Manager
Am Test Inc.
14603 N.E. 87th St.
Redmond, WA 98052
(425) 885-1664
www.amtestiab.com
_9UWMT
L A B O R A T O R 1 E S
Drinking Water Report for IOC's
Professional
Analytical
Services
System ID No.:
System Name:
Lab/Sample No: 06605783
Date Collected: 05/20/2008
DOH Source No: SO4
Multiple Source Nos.:
Sample Type:
Sample Purpose:
Date Received: 5/20/08
Date Reported: 5/23/08
Supervisor: AY
Date Digested:
Date Analyzed (Nitrates):
Analyst:
County: Jefferson
MO
Group:
Sample Location: 5/20/08 1000 American Campground
Send Report To: Bender Consulting
630 6th St S
Kirkland, WA .98033
y
Bill To: Scott Bender
630 6th St S
= �; �' = -.Kti( land; WA 98033
EPA Reaulated (Secondarvl - IOC's
DOH#
Analytes
Results
Units SRL
Trigger
MCL Exceeds MCL
Method
I Analyst
21
Chloride
ND
mg/I 20.
250
250 NO
300.0
MO
NOTES:
SRL (State Reporting Level): indicates the minimum reporting level required by the Washington Department of Health (DOH)
Trigger Level: DOH Drinking Water response level. Systems with compounds detected at concentrations in excess of this level are
required to take additional samples. Contact your regenional DOH office for further information.
MCL (Maximum Contaminant Level): If the contaminant amount exceeds the MCL, immediately contact your regional DOH office.
NA (Not Analyzed): in the results column indicates this compound was no included in the current analysis.
ND (Not Detected): in the results column indicates this compound was analyzed and not detected at a level greater than or equal
to the SRL.
<(0.001): indicates the compound was not detected in the sample at or above the concentration indicated.
LA^M- 1,) N A _'-T
aron W. Young
Laboratory Manager
q,Fw _.tea- -
VWP-1
15 r 36
VWP-6
12, 20,
21, 23,
` VWP-3 MW -5 MW -4
24, 29, 10, 11,
38,40 22, 44, MW -8
45
•.;
Proposed New
Well Location
HOOD CANAL
Notes: -
1) Well locations are approximate. Domestic well locations Monitoring Well Location =monitoring
pie
well; VWP =vibrating wire piezometer
typically to nearest quarter quarter unless better known.
2) See Appendix for well logs is Water Supply Well Location
Pleasant Harbor Marina and Golf Resort Domestic Well and Project Number
Subsurface Group, SG0601-03
LLC Groundwater Impact Evaluation Monitoring Well
Statesman Corporation Locations Figure 1
PLEASANT HARBOR NEIGHBORHOOD WATER SUPPLY PROGRAM
APPLICATION NO. G2-30436
February 24, 2010
The following four elements to protect existing water rights concern water right
application no. G2-30436:
1. Monitorina Proaram
This monitoring program meets and exceeds all requirements for a High Risk
SIPZ zone as defined by Jefferson County. Though Pleasant Harbor is not
located in a high-risk zone, the resort has committed these resources to assure
its neighbors and the County that the aquifer is being wisely used and protected.
A copy of the Pleasant Harbor Groundwater Monitoring Plan, as revised
February, 2010, is attached and incorporated herein ("monitoring plan").
The following summarizes the monitoring program
(a) Water quality samples will be collected on a quarterly basis.
(b) Flow meters will be installed.
(c) Pleasant Harbor will have a very thorough network of monitoring
wells (8) which will be used to document draw down conditions in
the aquifer.
(d) The network will include monitoring aquifer salinity conditions on
one-half hour increments.
(e) The locations of Pleasant Harbor wells will be located over 1,000
feet from any neighboring well or the shoreline.
(f) The existing well has supplied water at similar to proposed rates
with no adverse impacts (chlorides = 0).
(g) Hydrogeologic analysis is completed.
(h) Pleasant Harbor will route all site water into the aquifer in such a
manner that the aquifer will actually be receiving more water than
under existing natural conditions.
(i) This program will be continued for five years or until the resort has
achieved full build -out, whichever is longer.
2. Recharge Areas. Pleasant Harbor will set aside recharge areas to
mitigate an impact scenario or provide access (connect) to neighboring parcels to
Neighborhood Water Supply Program - Page 1
the Pleasant Harbor water system in the event of a problem with increased
chlorides (we also have the option to drill them a new well). The identification of
an impact is already presented in the County's SIPZ program.
3. Initial Mitigation Measures. If the monitoring program and evidence of
increased chlorides in neighboring wells show a probable salt water intrusion
impact on the wells from Pleasant Harbor's withdrawal of groundwater, Pleasant
Harbor will implement a plan to mitigate or minimize such impact by considering
lower pumping rates and/or adding points of withdrawal, in addition to recharge
as provided in paragraph 2 above.
4. Water Supply Replacement. In Jefferson County's approval of the FEIS
completed for Pleasant Harbor, Jefferson County has included condition P, the
Neighborhood Water Policy, which requires Pleasant Harbor to provide access to
its water system by any neighboring parcels if salt water intrusion becomes an
issue for neighboring wells on Black Point. Statesman proposes to expand and
define the terms of this policy as a condition of the water rights, as follows.
If the initial mitigation measures stated in paragraphs 2 and 3 above do not
correct or resolve the salt water impacts detected by the monitoring program,
Pleasant Harbor will offer at its cost sufficient mitigation and/or replacement
water for potable water for any existing home on a well that has an increase in
chloride levels as follows and under the following conditions:
(a) The neighboring resident's well is within the radius of influence of
the Pleasant Harbor wells. Until such time that Ecology has
sufficient evidence to delineate this area of influence, wells located
on the Black Point Peninsula in the same aquifer as Pleasant
Harbor's wells are covered by this neighborhood policy.
(b) The well owner provides conclusive evidence that, over a
statistically relevant period of time, chloride levels have increased
over chloride levels in the well prior to Pleasant Harbor's use of
groundwater, including but not limited to, evidence that the increase
in chloride levels is from the Pleasant Harbor groundwater use and
not from the construction of the well owner's well, and the data from
the monitoring program is consistent with the increase in chlorides.
As a default standard, Pleasant Harbor will provide an alternative
water supply if chlorides in a well exceed baseline (pre -Pleasant
Harbor groundwater use) by 15% that results in levels above 200
mg/I; or levels increase by 30% that results in levels above 100
mg/I over a 12 -month period (250 mg/I is the SDWA standard).
(c) Pleasant Harbor has the right to request additional evidence from
the resident showing that the Pleasant Harbor groundwater
withdrawal is the cause of the increase in chlorides if the increase
Neighborhood Water Supply Program - Page 2
is isolated to one well, the increase is likely caused by another
problem, and the only reasonable water replacement is a new well.
(d) The monitoring program will be continued for five years or until the
resort has achieved full build -out, whichever is longer. After this
period, the level of monitoring may be decreased unless there is
significant data showing increased chlorides, and Ecology
determines the monitoring program must be continued.
(e) If Pleasant Harbor provides replacement water from the Pleasant
Harbor system, it may apply for consolidation of the water rights
under RCW 90.44.105. The well owner will waive any claims
against Ecology or against Pleasant Harbor for any impairment of
the water right if Pleasant Harbor offers a reasonable alternative
source as provided above.
Neighborhood Water Supply Program - Page 3
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